Published on:

Judge Robinson denies Rule 12(c) motion on patentability of Intellectual Ventures’ patent relating to image scanning method for a scanner

Judge Sue L. Robinson recently considered and denied Ricoh Americas Corporation’s motion for judgment on the pleadings that Intellectual Ventures I LLC’s image scanning method patent is invalid under 35 U.S.C. § 101.  Intellectual Ventures I LLC v. Ricoh Americas Corporation, et al., C.A. No. 13-474-SLR (D. Del. Mar. 22, 2016).  Ricoh argued that the patent “‘simply claims an unpatentable mathematical formula used in a generic prior art scanner,’ which formula can be performed mentally or with a pen and paper.”  Id. at 14.  Judge Robinson disagreed, noting that the asserted claim does not claim a mathematical formula or method to implement such a formula.  Id.  Therefore, Judge Robinson concluded that the claimed invention was not directed to an abstract idea.  For “completeness” Judge Robinson analyzed step 2 of the Alice framework, i.e., whether the claims recite a known business practice merely implemented using computer technology.  Id. at 5.  Judge Robinson analyzed the claim language and concluded that it described with “sufficient specificity” how the claimed method operates the scanner, “thereby disclosing an ‘inventive concept.'”  Id. at 15.

Contact Information